Background
Paul D. Carr, a California state prisoner, filed a pro se action under 42 U.S.C. Section 1983 alleging that a defendant doctor acted with deliberate indifference to his serious medical needs by adjusting his prescription medications. The district court granted summary judgment in favor of the defendant.
The court’s reasoning
The panel reviewed the case de novo and affirmed the district court’s decision. The court found that Carr failed to raise a genuine dispute of material fact as to whether the defendant acted with deliberate indifference. The court noted that a difference of opinion between a physician and a prisoner concerning appropriate medical care does not amount to deliberate indifference. Additionally, the court rejected Carr’s contentions that the defendant committed perjury or submitted a sham affidavit, finding these unsupported by the record.
What it means going forward
The decision reinforces that medical disagreements alone do not establish a constitutional violation in prison medical care cases and limits the scope of claims that can survive summary judgment.
Podcast (federal-narrative-summaries): Play in new window | Download